Mar 17
2010

Citizens for Healthy Communities

FOR IMMEDIATE RELEASE:  March 17, 2010

March 19th Chemung Economic Forum Comes Under Fire
Chemung County Chamber of Commerce’s March 19th Economic Forum on natural gas drilling in the Southern Tier, to be moderated by Chemung County Executive Thomas Santulli, is being criticized for prohibiting the public and including presentations dominated by the gas industry and its supporters.  Although the Forum, scheduled for Friday, March 19 at 7:30 am at the Holiday Inn-Riverview in Elmira, was advertised as open to the public, many people who called for reservations to the event were turned down.

“When I called on March 3, I was told that the Forum was sold out,” said David Walczak of Bath, “but others who called for tickets to the breakfast were told that the event was only open to members of the Chamber.”

The scheduled speakers at the forum are heavily biased toward the gas industry.  They are natural gas industry officials from Chesapeake Energy Corp and Schlumberger, Inc., a representative of the Pennsylvania College of Technology who has spoken out extensively in support of hydraulic fracturing drilling of the Marcellus Shale and someone from Cornell University.

“If the Economic Forum was merely a private Chamber of Commerce meeting, they would certainly have every right to exclude non-members,” said Mark Schlechter, a resident of Steuben County, ”but the participation of the County Executive, and possibly other elected officials, turns the Forum into a public event.  The actions of the Chamber and the County Executive in excluding concerned members of the community raise questions about what will be discussed at the Forum and, more importantly, what decisions will be made by our elected leaders about gas drilling in our region.”

There is currently a moratorium on hydraulic fracturing, known as “fracking”, in New York State due to concerns about the environmental and economic effects of the drilling and plans to build a Schlumberger gas drilling service facility in Horseheads are on hold pending a State Supreme Court ruling on the issue.  A number of organizations have formed in area counties to raise public awareness of the hazards of injecting and storing millions of gallons of toxic-laced water into the ground and of the numerous examples of water contamination, air pollution and noise and odor complaints in other states where fracking has occurred.

“If public policy is to be set through closed forums such as the one moderated by our County Executive, then the public has a right to know what is being said and which elected officials are in attendance,” said Patricia Ladley, a Chemung County resident. ”This issue is too important to the health and economic well-being of our communities for us to be excluded.”

Tags: , , ,



Trackback  •  Posted in Community Effects, The Fox is Guarding the Henhouse  


Mar 16
2010

From the Star-Telegram, January 14, 2010:

In D-FW, ‘sobering’ asthma numbers

Look at a third-grade class or a youth soccer game, and start counting.

“One, two, three, asthma; one, two, three, asthma,” said Larry Tubb, senior vice president for system planning at Cook Children’s Health Care System. “That’s sobering.”

It represents a growing health problem in North Texas, where 1 in 4 children ages 8 and 9 has the lung disease. The state average for 5- to 9-year-olds is 7.1 percent; the national average for all children is 9.4 percent.

-end of article excerpt-

Now, why would the Dallas-Fort Worth area have a childhood asthma incidence that’s more than 2.5 times the national average?

Tags: ,



Trackback  •  Posted in Bad Neighbors, Community Effects, Cost Externalization, Mean Energy  


Mar 16
2010

.

Now, if natural gas is such a “clean” fuel, why d’ya suppose they’d do that?

From the newsletter of the American Petroleum Institute:

API backs resolution to block EPA from regulating carbon emissions
The American Petroleum Institute was among the oil and natural gas groups that signed a letter expressing support of Sen. Lisa Murkowski’s, R-Alaska, resolution against the Environmental Protection Agency’s plan to regulate greenhouse-gas emissions. Energy prices could increase and many jobs would be affected under the agency’s proposal, according to the letter. Oil & Gas Journal (3/11)

Natural gas suppliers oppose EPA’s GHG regulations: The Natural Gas Supply Association announced its support of a resolution sponsored by Sen. Lisa Murkowski, R-Alaska, that would stop the Environmental Protection Agency from regulating greenhouse-gas emissions. The agency’s proposed rule would “burden many natural gas projects with a time-consuming permitting process that would interfere with bringing more natural gas to market,” said trade group CEO Skip Horvath. The Wall Street Journal/Dow Jones Newswires (3/11)


For more on Senator Lisa Murkowski, see A Lobbyist Finds His Senator



Trackback  •  Posted in Cost Externalization, Mean Energy, Natural Gas Industry Lies  


Mar 15
2010


Letter to Edmonton Journal: “Letting gas companies have their way has devastating results”

Edmonton Journal

March 15, 2010

Re: “Natural gas and its ‘Drill, baby, drill’ conundrum,” The Journal, March 8.

I am a central Pennsylvania native who lives in the midst of the Marcellus shale region. I cannot begin to describe how devastating it is to witness the wholesale destruction of this once strikingly beautiful state by natural gas firms from both the United States and Canada. If you are a gas company executive living in Edmonton or Calgary for example, you do not have any ancestral bonds or other firsthand knowledge of this predominantly rural and less wealthy corner of the United States. Instead, your singular goal is to extract the natural gas and, accordingly, reap substantial profits. Meanwhile, massive and permanent environmental damage will be the only legacy of the Marcellus shale drilling left for Pennsylvanians. Although drilling only started less than two years ago, the state’s freshwater supplies (including the Susquehanna River, which flows into Chesapeake Bay) are already being depleted at an alarming rate and the forests and farmlands systematically destroyed. So, whenever energy experts like Peter Tertzakian or anyone else raises the “drill, baby, drill” credo, please remember that whatever economic gains are being derived from retrieving natural gas in the Marcellus shale region via hydraulic fracturing, they are coming at a terrible environmental cost comparable to that of the oil-sands, or perhaps even worse.

Marsha Ann Tate, Pleasant Gap, Penn.



Trackback  •  Posted in Community Effects, Cost Externalization, On the Bleeding Edge  


Mar 14
2010

Last month the American Petroleum Institute announced it was hiring a “grassroots” organizer (actually, it’s a stretch to call anything The Nature Conservancy does “grassroots” – but that’s a slightly different story, which we’ll come back to below).

Grass-Roots Organizer Jumps From Nature Conservancy to API

By ANNE C. MULKERN of Greenwire – February 26, 2010  nytimes.com

The oil industry’s biggest trade group has nabbed one of the environmental community’s top grass-roots organizers as it ramps up efforts to build a network of citizen lobbyists.

Deryck Spooner, who ran Nature Conservancy’s push to spur legislative action on climate change, will now head American Petroleum Institute’s grass-roots activism arm. The hiring move sends a nervous flutter through environmental groups. By recruiting Spooner, green groups said, API adds someone with both credibility and deep knowledge of grass-roots strategy. Spooner previously ran campaigns for labor group AFL-CIO and abortion rights organization NARAL.

“He’s a big dog,” said Tyson Slocum, energy program director at watchdog group Public Citizen. “It gives API somebody with enormous grass-roots experience running major campaigns. This indicates that API is taking their grass-roots strategy in a very serious direction.”

The move comes two months after the trade group cut 15 percent of its staff and President Jack Gerard said API had “not been as effective as we could be in educating public officials or the public about the critical role of oil and gas in our economy. … You will see us evolve into a more nimble, more aggressive” organization. “We’re going to be aggressive in our outreach to educate the public,” he said (E&ENews PM, Dec. 11, 2009).

Hiring Spooner is part of Gerard’s strategy to expand grass-roots activism, API spokeswoman Cathy Landry said, adding, “Jack’s vision is to mobilize the 9.2 million people whose jobs rely on the oil and gas industry. We do plan to step that up.”

API’s community activism last year sparked controversy, as environmental critics accused the trade group of steering employees to rallies aimed at killing climate legislation. API said the rallies allowed both employees and other citizens to voice concerns that climate legislation would raise energy prices and affect jobs.

Spooner, 42, doesn’t see the move from Nature Conservancy to API as that big of a jump.

“I have worked for vastly different organizations throughout my career,” Spooner said. “The bottom line is it’s all about advocacy, that’s what I’m passionate about. Mobilizing and organizing people to influence the public process and public policy is what I truly love to do.”

“At the end of the day, I don’t necessarily believe that the views of [the Nature Conservancy] and API are incompatible,” Spooner added. API members use technology “to ensure that the places that they drill are not impacted,” Spooner said, while the Nature Conservancy uses a scientific approach in deciding where to protect land and water. API members, he said, “don’t just want to drill anywhere for drilling’s sake. There’s a lot of science going into where they drill.”

. . . .

“There’s no useful contribution that the American Petroleum Institute is making to forwarding our energy economy,” said Kert Davies, research director for Greenpeace. “They’ve been at the center of campaigns to derail climate progress for 20 years.”

Ramping up grass-roots efforts with Spooner shows API believes that’s what’s necessary to achieve its goals, he said.

“They know that ultimately it’s going to come down to a grass-roots toe-to-toe battle on energy policy,” Davies said. And having Spooner at API gives the oil trade group new advantages, he said, including information about environmental group strategies.”

For complete NYTimes article, click here

And now, the other shoe – API’s version of grassroots.  How’s about some petrochemical-based synthetic dyes to make that astroturf look like the real thing? – sort of.  From API’s “Energy Tomorrow” website:

____________________________________

Yup, that’s the industry’s other major asset: shamelessness.  Watch for ongoing efforts to rebrand thoughtless over-consumption as “Domestic Access.”  Thanks to the ongoing efforts of industry leaders to exploit every possible drop of hydrocarbons during their own lifetimes, while they can hoard the profits, there may be an “Energy Tomorrow”  of sorts, but an “Energy Day After That” becomes somewhat more problematic.

Thanks to The Nature Conservancy for being so without ethics that it will apparently hire any amoral crook if s/he’s clever enough.   No wonder real climate-protection legislation hasn’t come to pass and isn’t on the horizon either.  This is why the bottom is falling out from under the big environmental organizations – they’ve forgotten their [grass]roots.

Tags: , ,



Trackback  •  Posted in General, Natural Gas Industry Lies  


Mar 14
2010

*Substitute your state environmental regulating agency

Guest post by Lynn Senick:

.

  • On Feb. 2, DEP fined Talisman Energy $3,500 for violations at its “Cease” well pad in Troy Township discovered during inspections in 2009.

    • A February 2009 inspection revealed that the company had not publicly posted the permit number and other required information at the entrance of the well pad. During a follow-up inspection in June 2009, a DEP statement explains, “flow-back fluids — or the fluids that are used to break up underground rock and then return to the surface — were found discharging into a drainage ditch, an adjacent sediment basin, and eventually through a vegetated area into an unnamed tributary of the south branch of Sugar Creek.” The Daily Review

  • “A vertical drilled well in The Marcellus Shale zone costs $810,000 to drill while a horizontal drilled well will cost you roughly 3-5 million dollars.” oilshalegas.com
  • In the Marcellus shale, Talisman drilled nine gross (nine net) wells during the quarter, for a total of 12 gross (12 net) in the first half of the year. The development plan is ahead of schedule and the company is now producing at rates in excess of 30 million cubic feet of gas per day. ugcenter.com

    • .

    COST OF DRILLING ONE HORIZONTAL WELL; $ 4 MILLION

    A FINE OF $3500 is 0.0875%  – the value of a a used Chevy Caravan.

    VALUE OF CLEAN AIR, LAND, & WATER?

    PRICELESS

    .

    Tags: , , , ,



    Trackback  •  Posted in Bad Neighbors, Community Effects, Gas Drilling Accidents, General, Mean Energy, The Fox is Guarding the Henhouse  


    Mar 14
    2010

    photo credit The Daily Star

    Excerpt from The Daily Gazette, Schenectady, NY on the pipeline explosion in North Blenheim, NY, twenty years ago on March 13, 1990:


    Effects of deadly blast still felt

    EDWARD MUNGER JR

    Earth scarred by the massive explosion that rocked this rural Schoharie County town 20 years ago has since healed and buildings reduced to smoldering rubble have long since vanished.

    But people who recall the sudden death of two neighbors and the devastation caused when a pipeline burst say they don’t expect to ever forget the fateful morning of March 13, 1990.

    The pipe carrying liquid propane, running north of state Route 30 near West Kill Road in North Blenheim, ruptured and sent a cloud of flammable gas drifting downhill.

    The cloud exploded about 7:30 a.m. when it got to the intersection of Route 30 and West Kill Road, killing Blenheim resident and firefighter Robert Hitchcock, 53, and Central Bridge resident Richard Smith, 43. The explosion destroyed 14 homes and injured five people.

    New gear added to the pipeline’s infrastructure and town buildings built after the blast — dedicated in honor of Hitchcock –  stand as reminders of the devastation today.

    And in the 20 years since, more stringent regulations governing pipelines and an added emphasis on safety have accompanied a 10 percent reduction in serious accidents, a government spokesman said.

    North Blenheim resident Peter Giesin recalls being in the cellar of his West Kill Road farmhouse when his daughter called to him asking what was going on in the field outside their home.

    “I looked out, there’s this white plume. At the time, I thought it was smoke. I thought an airliner had crashed or something,” Giesin said.

    The white cloud was a plume of gasified propane that leaked out of the Texas Eastern Products Co.’s underground pipeline — a pipeline run underground in the 1960s despite resident opposition that was ultimately overpowered by eminent domain.

    “I realized it was the pipeline blowing this plume of gas across the field which, naturally, was going downhill away from us. Then, within less than five minutes, a ball of fire came back over the hill from downtown where it ignited,” Giesin said.

    “The village looked like a war scene. It was just destroyed,” said Blenheim resident Gail Shaffer, who was working as secretary of state in Albany and rushed to the scene.

    “When we got to the village, it was all charred remains of buildings. There were 12 or 15 different fire companies with their hoses still on. It was organized chaos at that point,” Shaffer said. “I will never forget.”

    photo credit The Daily Gazette

    Today, offshore and onshore gas transmission lines carrying hazardous liquid such as propane stretch for more than 2.5 million miles in all 50 states, according to the federal Pipeline and Hazardous Materials Safety Administration, or PHMSA.

    New York state accounts for a total of 53,275 miles of underground pipelines.

    PIPELINE MAINTENANCE

    Following the 1990 disaster in North Blenheim, engineers hired by the government determined that several months before the accident, workers from the pipeline company raised the pipe to insert a rubber washer between it and a casing pipe around it. The work was in response to a short circuit detected in the system that uses a small electrical charge to keep the pipe from corroding.

    Engineers at the time said the crew filled the pipeline hole back in but the dirt might have been frozen. Once thawed, it allowed the pipe to settle and a weak point in the pipe — a manufacturing defect — broke in half.

    A National Transportation Safety Board investigation that followed criticized the fact that the pipeline’s operators were unable to detect a drop in pressure when the pipe leaked; the nearest monitoring location was in Gilbertsville, Otsego County, about 15 miles west of Oneonta and roughly 68 miles from North Blenheim. Afterward, the pipeline company installed remote terminal units to monitor the pressure at pump stations and receiving stations.

    The same 4,200-mile-long pipeline, which stretches from Texas to Selkirk, Albany County, sprang a leak in January of 2004. An explosion that followed destroyed one home in Delaware County but no injuries were suffered.

    Engineers determined the 2004 pipeline leak was caused by frost heave separating a valve from the pipe. Roughly 5,000 gallons of propane in the pipe burned for three days after the blast.

    In the 20 years since the blast in North Blenheim, the federal Department of Transportation has created the Pipeline and Hazardous Materials Safety Administration, expanding the department’s inspection and enforcement abilities and doubling the number of inspectors and accident investigators, said Damon Hill, a spokesman for the federal DOT.

    “Since then, we’ve had a number of regulations introduced that includes regulations for [pipe] integrity management programs, operator qualifications, control room management and quite a few other things to help make pipelines a lot safer,” Hill said.

    Among the new standards is a requirement that pipelines be capable of undergoing an internal inspection, he said.

    The “call before you dig” number was developed after the Schoharie County explosion, Hill said, to help stem third-party damage to pipelines he said are responsible for the bulk of pipeline failures today.

    The pipeline changed hands in terms of ownership, with TEPPCO merging with Enterprise Products Partners LP in October of 2009, Enterprise spokesman Rick Rainey said.

    Complete story available for fee from The Daily Gazette

    Tags: ,



    Trackback  •  Posted in Bad Neighbors, Community Effects, Cost Externalization, Mean Energy  


    Mar 13
    2010

    TO:
    Attn: dSGEIS Comments
    Bureau of Oil & Gas Regulation
    NYSDEC Division of Mineral Resources
    625 Broadway, Third Floor
    Albany NY 12233-6500
    dmnsgeis@gw.dec.state.ny.us

    FROM:
    Brian Brock, retired geologist
    Franklin NY

    DATE:
    30 December 2009

    RE:    CONSIDERATIONS  FOR  REVISIONS  TO  dSGEIS

    Aquifer Depths, Database of BOGR states that depths to the base of aquifer is so poorly known that they need to set a default value of 850 feet.  Despite this, there in no mention of a database for the driller’s report of the depth of fresh and brine waters at each well, which could be then used to predict depths to the base of the aquifer for future well permits.

    Bedding Planes and Fractures Flow of groundwater is usually controlled by these discontinuities, but there is no adequate discussion of bedding planes and fractures in Chapter 4, Geology.  Large roadcuts, quarries, railroad tunnels, and aqueduct tunnels can provide data.

    County Health Departments Many have neither the expertise or resources to investigate reports of water pollution, as suggested by SGEIS.  This responsibility is an unfunded mandate.  Health departments from counties in the fairways of the black shales should provide input.

    Cumulative Impact Draft SGEIS has only a few scattered and brief discussions of this.  If a boom in extraction of gas from black shales develops in NYS (as it has elsewhere), then cumulative impacts will be substantial.  Final SGEIS should have comprehensive Cumulative Impact Assessment to include: water withdrawal, waste disposal, traffic, road damage, air pollution, manpower, and community.  Current SEQRA handbook covers cumulative impact.

    Disclosure of Frac Chemicals to Public While BOGR requires that companies report all chemicals used to them, there is no provision for releasing this information to the public.  These chemicals will be injected below the public’s property and might contaminate the public’s drinking water.  Without such information, the public can not monitor the purity of its drinking water.

    Fairway, Extent of Alpha Environmental consultants defines “fairway” by rock properties (pages 4-14 and 4-18) without considering the setting of the rock units.  As a result, Fig. 4.7 and 4.12 show fairways of Utica and Marcellus shales extending north and east to outcroppings.  Production of economic quantities of gas require the hydrostatic/lithostatic pressure differential produced by thousands of feet of overlying rock.  As drawn, these figures give the mistaken impression that areas that are immediately south and west of shale outcroppings will have gas extraction and should be revised.

    Faulting
    Figure 4.13 gives the mistaken impression that the fairways for Utica and Marcellus shales are mostly free of faults — faults that could provide pathway for waters from black shales to aquifers.  True the figure is labeled “Mapped Faults …”, but the distinction between mapped faults and total faults is not discussed.   The bedrock is monotonous and poorly exposed, so probably many faults have gone unmapped.  This figure is based on a compilation over 30 years old, and could be updated with data from natural seismicity, seismic imaging, and mapping from NYC reservoir and tunnel construction.

    Figure 5-1 This schematic of a well pad  is confusing at best, and much of it is wrong.  If it is of a multi-well pad in development, then it should be so labeled.  This figure should be completely redrafted.  There is too much wrong to detail here, but contact me if you want suggestions.

    Flowback Disposal
    Destination  Within months of the approval of the final SGEIS, wells will each begin producing hundreds of thousand or millions of gallons of flowback.  A safe way to dispose of this is required, but there appears to be none in NYS.  Draft SGEIS does not estimate the volume of flowback expected nor discuss which sites could accept this volume.
    Reporting  In Appendix 6, the proposed Environmental Assessment Form does not require reporting of frac fluids that leave New York State.  Given the lack of a significant disposal option in state, most of this water may be sent out of state.

    Formation Waters, Composition of Draft SGEIS provides a summary of flowback analyses but not analyses of formation waters, despite BOGR regulating gas drilling for over a century.  Without such, several key points of the SGEIS can not be finalized, including:
    * How can formation waters be distinguished from flowback?
    * Can formation waters be processed through POTW?
    * Can formation water be safely spread on roads?

    Frac Trespass
    CI Hearings Currently a hearing for compulsory integration can be held after well work is completed as long as land has been leased where drilling takes place.  Presumably a frac job is designed to fracture throughout entire drilling unit.  May they frac before the whole unit is leased or integrated?
    Taking Fracing is a new technology with imperfect control of the extent of resulting fractures.  How can neighbors to the drilling unit be assured that fracing will not extend under their properties, neither trespassing nor taking “their” gas?

    Funding and Staffing Although this is outside the scope of SGEIS, until BOGR obtains adequate resources for enforcement, the public can have no confidence that GEIS and SGEIS are anything more than ink on paper.

    ICF International Analysis. Appendix 11
    Pore Flow The mathematical analysis of fluid flow through intact rock via pore space (pp. 24 – 31) is a pointless.  There is no doubt that 1000 feet of unfractured rock would provide a barrier to frac fluids over short times, but how often is this the case?
    Fracture Flow Despite wasting pages on calculating pore-flow rates, ICF dismisses chances of an open flow path from fractures, faults, or well bores as “theoretically possible but extremely unlikely” (pg. 31) without attempting to quantify this risk.  The experience of NYC in drilling their aqueduct tunnels suggest that the risk could be substantial.
    Reporting Fluid Flow Even if the odds of an open flow pathway “is very small” (pg. 32), given the large number of wells expected, then occurrence of open pathways is almost certain.   Therefore one of the required non-routine incidents that drillers should report (Appendix 10, Supplementary Permit Conditions, #46) should be failure to hold pressure or anomalous fluid loss during fracing.
    Injection Wells ICF consultants may be correct that high-pressure fracturing for a short time (“typically less than a day per stage”, pg. 34) make it unlikely that frac fluids could immediately reach aquifers.  On the other hand, injection wells do pump waste water at high pressures for longer times.  The consultants neglect to consider long-time flow of fluids from injection wells.  Injection wells remain one of the few ways to dispose of waste water from drilling, flowback, or plugging.
    Lack of Evidence The final conclusion (pg. 34): “There are no known incidents of ground water contamination due to hydraulic fracturing.” is deceptive.  Because there has been no testing of groundwater before and after fracing by either drillers or BOGR, it is more correct to say that no proof exists that groundwater remains uncontaminated due to hydraulic fracturing.  “Absence of evidence is not evidence of absence.”

    Incident Response With a large enough number of wells, everything that could go wrong will go wrong: surface spills, well seeps, aquifer pollution, fires, explosions, etc.   While SGEIS requires the reporting of any non-routine incidents by drillers, there is no mention of the response required by BOGR.

    Inspections
    Frequency For most wells, no inspections are required during the entire life cycle of a site: site preparations, drilling, fracturing, completing, and production.  (A single inspection during surface casing is required only for the minority of wells in primary and principal aquifers.)  Considering that much of the BOGR oversight is limited to the review of paperwork self-reported by drillers, a minimum number of random and unannounced inspections is necessary to encourage honest reporting and should be required.
    Surface Casing and Initial Fracing Site visits should be required for these two steps.  These two visits by Mineral Resource Specialists would also allow inspection of the general operation.  If this is beyond the current staff, it only argues for an increase in staffing.
    Transparency There is no written procedure for monitoring and inspecting a well over its life cycle from site preparation to production.  Without this, the public has no way to determine if BOGR is fulfilling its responsibility to protect the environment.
    Workload BOGR has stated that it has and will continue to provide sufficient oversight of each gas well.  Should there be a rush of permit request, the number of permits issued would be limited by the workload of mineral resource specialists.  Neither final GEIS nor draft SGEIS lists what the workload is for permitting and oversight of a single well.  Nor is there a limit to the number of active wells in a mineral resources specialist’s caseload.  Without such information, the public can not be assured that BOGR is providing sufficient oversight.  Without sufficient oversight, GEIS and SGEIS are only ink on paper.

    Loss of Springs and Wells During the drilling of the first several hundred feet through aquifers, there is a risk of loss or fouling of neighboring water sources until the surface casing is cemented.  Special attention in inspection or reporting should be required during this period.

    LPG Fracing If this water-free fracing may someday be proposed for use in NYS, will a second SGEIS be required?  Wouldn’t it make sense to include this technology in the current SGEIS?  Obtaining and disposing of millions of gallons of water for each well constrains future fracing.

    Metering Currently BOGR does not require periodic recertification of gas meters at well heads, spot check reading of meters that is done by companies, or audit company records – procedures that are routine in other states.  (These deficiencies were cited in NYS Comptroller audit 2005-S-54.)  Such procedures are required to assure that landowners and state receive what are legally due them.  The much greater volumes of gas produced by horizontal wells make a true accounting all the more important.

    Methane in Groundwater Draft SGEIS mentions that methane naturally occurs in groundwater.  It does not discuss that this proves that there are pathways between black shales and aquifers — although not necessarily the targeted shales.  Gas is much more buoyant and less viscous than frac fluid, and therefore it is not clear how much of these fluids would follow the same pathways and over what time.  Nevertheless the nature and implication of these pathways should be discussed.

    Multiple Plays There is substantial overlap of the fairways for Marcellus and Utica shales.  A smaller area additionally includes the fairway for Herkimer tight sandstones.  (Indeed Nornew brags that it has this “triple play” in Madison and Chenango Counties.)  There is also a chance of the spotty occurrence of Trenton/BlackRiver plays   Multiple plays multiply the effects at each well pad, but the draft SGEIS ignores the effects of multiple plays of gas, particularly on cumulative impacts.

    Pollution
    Bonding Drillers should be bonded for the clean-up of any pollution caused by their activities.  (Currently they are bonded only for plugging well and restoring the site.)  Commonly companies will set-up a shell company for drilling each well with assets just sufficient to cover expenses.  Without bonding, should there be major pollution, the company has no reserves that could recovered for the clean-up.
    Database BOGR can state that it knows of no incident of pollution from fracing in NYS.  This claim can not be confirmed because BOGR does not maintain a database of reports of pollution.  Such a database should be built.
    Liability In neighboring Pennsylvania, any pollution within 1000 feet of well head is presumed to be the responsibility of the driller who must provide sufficient water and remediate the pollution to the satisfaction of DEP.  (Purity of the provided water must be independently certified.)  There is no such provision in the final GEIS or draft SGEIS.  Without it, a individual land owner could have the expense and aggravation of dragging a polluting company through the courts for years to get satisfaction, whereas the owner needs are immediate.
    Risk Despite BOGR statement that there are no case of pollution of aquifers from fracing, there are numerous documented cases of pollution of aquifers from gas drilling.  To the land owner who has lost their drinking water and a much of the value of their property, the distinction between drilling and fracing is academic.  The SGEIS should more fully discuss causes of pollution during the entire drilling process and how to eliminate any causes not covered in GEIS.

    Publicly-Owned Treatment Works, Appendix 21 Despite this list of 135 POTWs, there is no guarantee that a single one of these works is capable of treating of produced waters, from drilling, flow back, or plugging.  POTW do not remove the chemicals from these waters but only dilute the toxins to below legal limits.  All the toxins are dumped into the river.  Without representative analyses of produced waters, it is not possible to even know if it is safe to pass these waters through these works or what dilution is required.  Indeed the vast majority of operators are not even considering applying for permission from DEC to accept this waste.  Including this long list in the SGEIS deceptively give the impression that there are many possible sites to receive the waste waters produced.

    Refrac Permits Black shales in NYS may be refraced as soon as one year after the initial frac – although five years is more typical elsewhere.  Draft SGEIS requires a permit for refracing (8.3.2), but does not specify what information will be necessary to obtain this permit.

    Road Spreading of Produced Fluids Permitting for a Beneficial Use Determination for road spreading does not specify what are the acceptable concentration of pollutants.

    Set Backs, Residential GEIS requires set backs of 100 feet from drill pads to residences for a single well and this is not increased in the draft SGEIS.  This is the smallest setback of any state, with most having setbacks of 200 to 600 feet.  Even if this is adequate for single vertical wells, this is inadequate for single horizontal wells, let alone pads of multiple wells, multiple plays, and refacturings.  One site could be actively drilled and fractured for three years for a single play.

    Seismic Monitoring Fracing is a developing technology with an imperfect control of the extent of resulting fractures.  Without seismic monitoring during fracing, the owners of neighboring can not be assured that gas will not be withdrawn from beneath them.  At least for a trial period, this should be required for a few wells and the results reported.

    Toxicity of Chemicals Draft SGEIS does not compare the toxicity of chemicals used in drilling and fracing, claiming that there is no way to measure this: “there does not seem to be a US-based metric” pg. 9-10.  However the Federal Mineral Management Service does such rating of such chemicals in its capacity of regulator of off shore drilling. Their methodology should be applied to the land-based use of such chemicals.

    Trial Period Once the final SGEIS is adopted, BOGR should begin with a limited number of permits for the new horizontal drilling and high-volume hydraulic fracturing of low permeability gas shales — maybe one multi-well pad in each county.  After a formal review, the annual number of such permits could be gradually increased.

    Unconventional Gas Reservoirs While they are mentioned, it would help if there was a brief discussion of the differences among coal beds, tight sandstones, and black shales and of the differences in extracting gas from them.

    Water Testing
    Composition While water testing is required around the drill site, what is required to be tested does not include chemicals in frac fluids.  Without these, results  will be less useful for showing contamination.  What is more, this testing is not required to be done such that the results would be admissible in a court of law, thereby giving a false sense of security to the property owner.
    Location For vertical wells, testing within a circle1000 feet in diameter may be sufficient, but for horizontal wells, a corridor at least 330 feet on either side of the horizontal well bore should be included.  Without this, BOGR is assuming that fracing could never pollute aquifers and avoiding any evidence that could contradict.

    The Bureau of Oil and Gas Regulation is to be commended for compiling so much information for the SGEIS, but much work remains to be done.  Indeed, so much needs to be revised in and added to the draft SGEIS that a second round of comments will be necessary before the final SGEIS is adopted.  However from my experience with the public hearings this fall at Chenango Valley High School, comments should be limited to written submissions.



    Trackback  •  Posted in Community Effects, SGEIS, The Fox is Guarding the Henhouse  


    « Older Entries

    Newer Entries »